Institutional Conflict of Interest Program

Introduction

As the University of Wisconsin-Madison collaborates with an ever-expanding network of affiliated organizations to apply the fruits of research and
scholarship for the benefit of society, the potential exists for institutional conflict of interest. Institutional conflict of interest may arise when
the university or university officials have significant financial interests in the affiliated entities that collaborate with the university.

The university is committed to the disclosure, identification, and management of institutional conflict of interest. In addressing institutional conflict
of interest, the university seeks to protect the objectivity of research, teaching and outreach at the university; to avoid any compromise or appearance of
compromise to its integrity; and to ensure the proper protection of human subjects.

ICOI Policy Definitions

Institutional Conflict of Interest ("Institutional COI" or "ICOI") -
The institution may have a conflict of interest whenever the financial interests of the institution, or of a university official acting within his or her
authority on behalf of the institution, might affect - or reasonably appear to affect - institutional processes for the selection, design, conduct,
reporting, review, or oversight of the university enterprise. For the purposes of evaluating ICOI, activities related to research, teaching and outreach,
and the administration of those functions, singly and collectively, represent the University enterprise.

University Official
- University Officials covered under the UW-Madison's ICOI Policy are those officials who have the power to commit substantial resources of the university.
University officials include, but are not limited to, Chancellors, Vice Chancellors, Provosts, Vice Provosts and Deans, including those holding these
positions in an interim capacity, as well as others who have discretionary authority to allocate resources related to the university enterprise as
identified by any of the officials named previously.

Significant Financial Interest (SFI)
For purposes of evaluating an ICOI, the definition of a SFI will be similarly stated as it is in the Code of Federal Regulations at 42 CFR 50.603 (see,
complete definition in Appendix 1 of the UW-Madison ICOI Policy, below).

For more information about the UW-Madison ICOI Program, please refer to the ICOI Policy and ICOI Procedures documents below.